General Information IronBridge, a Delaware limited liability company, was formed in February 2017.
Advisory Clients IronBridge provides discretionary and non-discretionary portfolio management as well as financial planning and general consulting services to individuals, corporations, trusts, estates and charitable organizations.
At the outset of each client relationship, IronBridge spends time with the client, asking questions, discussing the client's investment experience and financial circumstances, and broadly identifying major goals of the client. Clients may elect to retain IronBridge to prepare a full financial plan. This written report is presented to the client for consideration, and in most cases, clients subsequently retain IronBridge to manage the investment portfolio on an ongoing basis.
For those financial planning clients making this election and for other clients who retain IronBridge for portfolio management services, based on all of the information gathered, IronBridge generally develops with each client:
•a financial outline for the client based on the client's financial circumstances and goals, and the client's risk tolerance level (the "Financial Profile"); and
•the client's investment objectives and guidelines (the "Investment Plan"). The Financial Profile is a reflection of the client's current financial picture and a look to the future goals of the client. The Investment Plan outlines the types of investments IronBridge will make or recommend on behalf of the client based on IronBridge's own research and analysis in order to meet those goals. The elements of the Financial Profile and the Investment Plan are discussed periodically with each client, but are not necessarily written documents.
Finally, where IronBridge provides only limited financial planning or general consulting services, IronBridge will work with the client to prepare an appropriate summary of the specific project(s) to the extent necessary or advisable under the circumstances.
Portfolio Management As described above, IronBridge will develop an Investment Plan with each portfolio management client. Based on the financial profile required by the custodian and an interview with the client, investment advice is tailored to each client's individual Investment Plan reflecting each client's needs and investment objectives. The Investment Plan will be updated from time to time when requested by the client, or when determined to be necessary or advisable by IronBridge based on updates to the client's financial or other circumstances.
To implement the client's Investment Plan, IronBridge will manage the client's investment portfolio on a discretionary or a non-discretionary basis pursuant to an investment advisory agreement with the client. As a discretionary investment adviser, IronBridge will have the authority to supervise and direct the portfolio without prior consultation with the client. Clients who choose a non-discretionary arrangement must be contacted prior to the execution of any trade in the account(s) under management. This may result in a delay in executing recommended trades, which could adversely affect the performance of the portfolio. This delay also normally means the affected account(s) will not 4 be able to participate in block trades, a practice designed to enhance the execution quality, timing and/or cost for all accounts included in the block. In a non-discretionary arrangement, the client retains the responsibility for the final decision on all actions taken with respect to the portfolio.
Notwithstanding the foregoing, clients may impose certain written restrictions on IronBridge in the management of their investment portfolios, such as prohibiting the inclusion of certain types of investments in an investment portfolio or prohibiting the sale of certain investments held in the account at the commencement of the relationship. Each client should note, however, that restrictions imposed by a client may adversely affect the composition and performance of the client's investment portfolio. Each client should also note that his or her investment portfolio is treated individually by giving consideration to each purchase or sale for the client's account. For these and other reasons, performance of client investment portfolios within the same investment objectives, goals and/or risk tolerance may differ and clients should not expect that the composition or performance of their investment portfolios would necessarily be consistent with similar clients of IronBridge.
Separate Account Managers When appropriate and in accordance with the Investment Plan for a client, IronBridge may utilize one or more Separate Account Managers (each, a "Manager"). Having access to various Managers offers a wide variety of manager styles, and offers clients the opportunity to utilize more than one Manager if necessary to meet the needs and investment objectives of the client. IronBridge will usually select the Manager(s) it deems most appropriate for the client. Factors that IronBridge considers in recommending/selecting Managers generally includes the client's stated investment objective(s), management style, performance, risk level, reputation, financial strength, reporting, pricing, and research.
The Manager(s) will generally be granted discretionary trading authority to provide investment supervisory services for the portfolio. Under certain circumstances, IronBridge retains the authority to terminate the Manager's relationship or to add new Managers without specific client consent. In other cases, the client will ultimately select one or more Managers recommended

by IronBridge.
In any case, with respect to assets managed by a Manager, IronBridge's role will be to monitor the overall financial situation of the client, to monitor the investment approach and performance of the Manager(s), and to assist the client in understanding the investments of the portfolio.
Financial Planning IronBridge also offers financial planning services, as described below. These services may be provided on a stand-alone basis or may be coupled with ongoing portfolio management.
It typically takes 4-6 weeks to develop a financial plan. The steps include the following:
•information gathering
•preliminary plan
•discussion with the client
•modifications if necessary
•client meeting to finalize the plan The financial planning process may take longer depending on the complexity of the client's financial needs and objectives.
5 Financial planning may include advice that addresses one or more areas of a client's financial situation, such as estate planning, risk management, budgeting and cash flow controls, retirement planning, education funding, and investment portfolio design and ongoing management. Depending on a client's particular situation, financial planning may include some or all of the following:
•Gathering factual information concerning the client's personal and financial situation;
•Assisting the client in establishing financial goals and objectives;
•Analyzing the client's present situation and anticipated future activities in light of the client's financial goals and objectives;
•Identifying problems foreseen in the accomplishment of these financial goals and objectives and offering alternative solutions to the problems;
•Making recommendations to help achieve retirement plan goals and objectives;
•Designing an investment portfolio to help meet the goals and objectives of the client;
•Providing estate planning;
•Assessing risk and reviewing basic health, life and disability insurance needs;
•Reviewing goals and objectives and measuring progress toward these goals;
•Providing advice to retirement and pension plan participants on diversification strategies and asset allocation; or
•Providing general investment education, which may include basic information regarding insurance products, mutual funds, annuities, inflation, risk and diversification. Once financial planning advice is given, the client may choose to have IronBridge implement the client's Financial Plan and manage the investment portfolio on an ongoing basis. Any financial planning fee may be waived at IronBridge's sole discretion if the client engages portfolio management services. However, the client is under no obligation to act upon any of the recommendations made by IronBridge under a financial planning engagement and/or engage the services of any recommended professional.
General Consulting In addition to the foregoing services, IronBridge may provide general consulting services to clients. These services are generally provided on a project basis, and may include, without limitation, minimal cash flow planning for certain events such as education expenses or retirement, estate planning analysis, income tax planning analysis and review of a client's insurance portfolio, as well as other matters specific to the client as and when requested by the client and agreed to by IronBridge. The scope and fees for consulting services will be negotiated with each client at the time of engagement for the applicable project.
Principal Owners James M. Denholm III is the sole principal owner of IronBridge.
IRA Rollover Recommendations Effective December 20, 2021 (or such later date as the US Department of Labor ("DOL") Field Assistance Bulletin 2018-02 ceases to be in effect), for purposes of complying with the DOL's Prohibited Transaction Exemption 2020-02 ("PTE 2020-02") where applicable, we are providing the following acknowledgment to you.
When we provide investment advice to you regarding your retirement plan account or individual retirement account, we are fiduciaries within the meaning of Title I of the Employee Retirement Income Security Act and/or the Internal Revenue Code, as applicable, which are laws governing retirement 6 accounts. The way we make money creates some conflicts with your interests, so we operate under a special rule that requires us to act in your best interest and not put our interest ahead of yours. Under this special rule's provisions, we must:
•Meet a professional standard of care when making investment recommendations (give prudent advice);
•Never put our financial interests ahead of yours when making recommendations (give loyal advice);
•Avoid misleading statements about conflicts of interest, fees, and investments;
•Follow policies and procedures designed to ensure that we give advice that is in your best interest;
•Charge no more than is reasonable for our services; and
•Give you basic information about conflicts of interest. We benefit financially from the rollover of your assets from a retirement account to an account that we manage or provide investment advice, because the assets increase our assets under management and, in turn, our advisory fees. As a fiduciary, we only recommend a rollover when we believe it is in your best interest.
Type and Value of Assets Currently Managed As of December 31, 2023, we provide continuous management services for $238,697,617 in client assets on a discretionary basis, and $771,622 in client assets on a non-discretionary basis.